Indonesian roundup: relaxation of 2025 annual CIT return sanctions

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Indonesian roundup: relaxation of 2025 annual CIT return sanctions

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Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting outline Indonesia’s relaxation of sanctions for late 2025 corporate income tax returns and payments, alongside updated rules on preliminary refunds and compliance requirements

On April 30 2026, the Indonesian Directorate General of Taxes (DGT) issued Decree No. KEP-71/PJ/2026 (KEP-71) stipulating the waiver of administrative sanctions for late filing and payment of the 2025 annual corporate income tax (CIT) return through the Coretax Administration System.

The highlights are as follows:

  • Waiver of administrative sanctions – corporate taxpayers are granted a full exemption from administrative penalties (including interest and fines) for late submission of the 2025 annual CIT return and late CIT payment/settlement (Article 29). This applies as long as the obligations are fulfilled within one month after the statutory deadline.

  • Automatic cancellation of tax bills – the DGT will not issue tax collection letters (STPs) concerning the above delays. If an STP is generated automatically by the system, it will be cancelled ex officio by the head of the respective regional tax office.

  • Protection of compliance status – any late submissions within this relaxation period shall not act as a basis for denying an application for ‘certain criteria taxpayer’ status.

The decree entered into effect on April 30 2026.

Coretax sanction waiver policy announcement

Following the issuance of KEP-71, the DGT released Announcement No. PENG-31/PJ.09/2026 to guarantee consistent operational implementation and transparent public communication concerning the regulatory relief policy.

The highlights are:

  • Reiteration of statutory deadlines – the DGT explicitly reminds corporate taxpayers that the normal statutory deadline for paying CIT (Article 29) and filing the 2025 annual tax return is four months after the end of the fiscal year;

  • Scope of application – the announcement clarifies that the waiver applies to the full fiscal year and any fractional fiscal year returns; and

  • Operational assurance – the announcement guarantees that fulfilling tax obligations up to one month after the normal deadline will result in the waiver of penalty and interest, without the issuance of an STP.

The measures became effective on April 30 2026.

New procedures for preliminary refunds of tax overpayments

The Indonesian Ministry of Finance issued Minister of Finance Regulation No. 28 of 2026 (PMK-28) on April 29 2026, which came into effect on May 1 2026. The regulation revokes and replaces PMK-39/PMK.03/2018 concerning the Procedures for Preliminary Refund of Tax Overpayment, along with its first, second, and third amendments.

The update is intended to ensure that the preliminary refund facility is granted in a more targeted manner, while balancing the fulfilment of taxpayers’ rights and obligations.

In general, PMK-28 does not eliminate taxpayers’ entitlement to preliminary refunds; rather, it introduces stricter provisions for taxpayers intending to apply for a preliminary refund of tax overpayments. The taxpayers eligible to apply for a preliminary refund are as follows:

  • Certain criteria taxpayers;

  • Taxpayers meeting certain requirements; and

  • Low-risk taxable ‘entrepreneurs’.

Under PMK-28, there is an expansion of provisions and a change in the limitations on applications for preliminary refunds. The key changes are outlined below.

No.

PMK-28

Previous provision

Type of taxpayer

1

Article 3, paragraph 4

The condition of having no outstanding tax liabilities as referred to in paragraph 2, letter b, shall mean:

· A taxpayer who does not have any tax liabilities that have exceeded the payment due date as of December 31 of the last year prior to designation as a certain criteria taxpayer, except for tax arrears for which approval for deferral or instalment payment has been granted, or that are already time-barred for collection; and

· A taxpayer who has never made any payment after the due date of tax liabilities for all types of taxes, including never making any late payment on approved deferrals or instalment arrangements, within the last five years prior to designation as a certain criteria taxpayer.

Article 4, paragraph 4

The condition of having no outstanding tax liabilities as referred to in paragraph 2, letter b, means that, as of December 31 of the last year prior to designation as a certain criteria taxpayer, the taxpayer does not have any tax liabilities that have exceeded the payment due date, except for tax arrears for which approval for deferral or instalment payment has been granted.

Certain criteria

2

Article 3, paragraph 5

Financial statements audited by a public accountant or a government financial supervisory institution, with an unqualified opinion for three consecutive years as referred to in paragraph 2, letter c, must meet the following requirements:

· They must be attached to the annual CIT return that is required to be submitted prior to designation as a certain criteria taxpayer;

· They must obtain an unqualified opinion, excluding an unqualified opinion with an explanatory paragraph (modified unqualified opinion);

· They must not constitute restated financial statements resulting from corrections of errors or manipulation of financial data, and must be accompanied by a statement letter from the taxpayer confirming compliance with the financial statement criteria;

· If there is a request for clarification of data and/or information regarding fiscal profit/loss issued at least three months prior to designation as a certain criteria taxpayer, the request must have been responded to or discussed in accordance with the prevailing tax laws and regulations;

· They must not be subject to corrections of fiscal profit/loss exceeding 5% based on the results of tax audits for the last three fiscal years prior to designation as a certain criteria taxpayer, which have been agreed upon by the taxpayer or have become final and legally binding (inkracht); and

· The public accountant conducting the audit must comply with the five-year limitation period for the provision of audit services on historical financial information as stipulated under the government regulation on public accountant practices, and such compliance must be supported by a statement letter from the taxpayer confirming fulfilment of the financial statement criteria.

Article 3, paragraph 5

Financial statements audited by a public accountant or a government financial supervisory institution as referred to in paragraph 2, letter c, are those that have been audited by a public accountant or government financial supervisory institution and attached to the annual income tax return, which must be submitted for three consecutive years up to the end of the year preceding the year of designation as a certain criteria taxpayer.

Certain criteria

3

Article 9, paragraph 2, letter d

Taxpayers meeting certain criteria as referred to in paragraph 1 include taxable entrepreneurs who file a periodic VAT return indicating an overpayment, with:

· Total taxable supplies of up to IDR 4.2 billion; and

· An overpayment amount not exceeding IDR 1 billion for each respective tax period.

Article 9, paragraph 2, letter d

A taxable entrepreneur who files a periodic VAT return indicating an overpayment and requests a refund, where the amount of the overpayment does not exceed IDR 5 billion.

Certain requirement

 

Furthermore, PMK-28 stipulates that taxpayers whose designation decisions are declared invalid, as referred to in letter a, may reapply for designation as certain criteria taxpayers from June 1 2026 to June 10 2026, or in accordance with the date given in Article 4, paragraph 1; i.e., January 10. Such taxpayers may subsequently be designated as certain criteria taxpayers within 30 working days from the date of application submission, provided they meet the requirements in Article 3 of PMK-28.

These changes are expected to improve taxpayer compliance – particularly among those applying for preliminary tax refunds – and provide greater legal certainty.

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